CERA SANITARYWARE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

ITA 1333/AHD/2024Status: DisposedITAT Ahmedabad07 February 2025AY 2020-21Bench: SMT.ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the AO's invocation of Rule 8D was justified as the assessee's explanation for suo moto disallowance was not satisfactory. However, the addition of Rs. 45,97,690 under Section 41(1) was deleted as it was already included in the assessee's returned income and constituted a double addition.

What were the facts?

The assessee earned exempt income and made a suo moto disallowance. The Assessing Officer (AO) invoked Rule 8D, disallowing a further amount. The assessee also argued that a Rs. 45,97,690 addition under Section 41(1) was a double addition as it was already accounted for.

What were the issues?

Whether the AO correctly invoked Rule 8D for disallowance of expenses related to exempt income, and whether the addition under Section 41(1) constituted a double addition.

Which sections of the Income-tax Act were involved?

Section 14A,Section 41(1),Section 143(1)(a)

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Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: SMT.ANNAPURNA GUPTA & SHRI T.R. SENTHIL KUMAR

For Appellant: Shri Dinal Shah, AR
Hearing: 03/02/2025Pronounced: 07/02/2025

आदेश आदेश आदेश

PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER

The above appeal has been filed by the Assessee against order passed by the ld.Commissioner of Income-tax (Appeal), National Faceless Appeal Centre (“NFAC”), Delhi dated 13.6.2024 passed under section 250 of the Income Tax Act, 1961 ("the Act" for short) pertaining to Assessment Year 2020-21. 2. Ground no.1 raised by the assessee reads as under:

1.

The learned CIT (Appeal

The order continues below.

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